Berry v. Commissioner
United States Tax Court
The G.B.M. Co., a partnership comprised of petitioners and two other partners, sold the Raleigh Hotel located in Washington, D.C., on October 26, 1953, for a stated purchase price of $ 3,240,000. Sellers took back an 11-year note in the stated amount of $ 1,548,739.10. The contract recites the note is to be without interest, but includes a prepayment discount schedule.
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The G.B.M. Co., a partnership comprised of petitioners and two other partners, sold the Raleigh Hotel located in Washington, D.C., on October 26, 1953, for a stated purchase price of $ 3,240,000. Sellers took back an 11-year note in the stated amount of $ 1,548,739.10. The contract recites the note is to be without interest, but includes a prepayment discount schedule. Earlier offer to purchase made by the buyer contemplated a purchase price of $ 2,800,000 with the sellers taking back a note bearing interest at 4 1/2 percent for the deferred payments. The discount schedule included in both…
1Opinion of the Court
Estate of Betty Berry, Deceased, Louis Berry, Executor, Louis Berry, Surviving Spouse, Petitioners, v. Commissioner of Internal Revenue, Respondent; L.C.G. Trust No. 2, A. R. Glancy, Jr., Successor Trustee, Petitioner, v. Commissioner of Internal Revenue, Respondent
Berry v. Commissioner
Docket Nos. 89806, 89963
United States Tax Court
43 T.C. 723; 1965 U.S. Tax Ct. LEXIS 121;
February 25, 1965, Filed February 25, 1965, Filed
Decisions will be entered under Rule 50.
The G.B.M. Co., a partnership comprised of petitioners and two other partners, sold the Raleigh Hotel located in Washington, D.C., on…
Also in this document: Dissent.
2Cases cited9 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Mills v. CommissionerUnited States Tax Court · 1948
- Brown v. CommissionerUnited States Tax Court · 1961
- Daniel Bros. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1928
- Elliott Paint & Varnish Co. v. CommissionerUnited States Board of Tax Appeals · 1941
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